Circumstantial Evidence Must Form an Unbroken Chain: Punjab & Haryana High Court Acquits Murder Convict as Last Seen Theory, Extra-Judicial Confession and FSL Evidence Failed to Prove Guilt Beyond Reasonable Doubt
Case Name: Naresh @ Kala v. State of Haryana
Date of Judgment: 21 July 2026
Citation: CRA-491-DB-2005
Bench: Hon’ble Mr. Justice Vinod S. Bhardwaj & Hon’ble Mrs. Justice Sukhvinder Kaur
Held: Allowing the appeal, the Punjab and Haryana High Court held that a conviction resting solely on circumstantial evidence can be sustained only when every incriminating circumstance is firmly established and forms a complete, unbroken chain pointing exclusively towards the guilt of the accused. The Court found that the prosecution failed to prove the last seen theory, the extra-judicial confession, motive, and the alleged recovery of incriminating articles. It further held that the FSL report did not establish that the stains recovered from the appellant’s shirt were of human blood, much less that they belonged to the deceased. Observing that suspicion, however grave, cannot substitute legal proof, the Court extended the benefit of doubt and acquitted the appellant of the charge under Section 302 IPC.
Summary: The appellant challenged his conviction for murder under Section 302 IPC, which was primarily founded on circumstantial evidence. According to the prosecution, the deceased had last been seen in the company of the appellant, who allegedly made an extra-judicial confession and subsequently led to the recovery of blood-stained clothes and bedding. The prosecution sought to establish a complete chain of circumstances comprising the last seen theory, extra-judicial confession, recoveries, medical evidence and forensic examination to prove the appellant’s guilt.
The High Court found that virtually every material circumstance relied upon by the prosecution had collapsed during trial. The principal witnesses who were expected to establish that the deceased was last seen with the appellant turned hostile and failed to support the prosecution. Likewise, the witness before whom the alleged extra-judicial confession was made, as well as another witness allegedly present during such confession, also resiled from their earlier statements. The Court reiterated that extra-judicial confession is inherently a weak piece of evidence and becomes even more unreliable when the witness himself does not support the prosecution. Consequently, the two principal links in the chain of circumstantial evidence remained wholly unproved.
The Court further observed that the alleged recoveries also failed to incriminate the appellant. The recovery of the quilt and mattress was not effected pursuant to any disclosure statement and therefore lacked evidentiary significance under Section 27 of the Evidence Act. Although the appellant’s shirt was recovered pursuant to a disclosure statement, the Forensic Science Laboratory reported that the stains had disintegrated and could not be identified as human blood. Accordingly, the prosecution failed to connect the recovered clothes either with the deceased or with the alleged offence. Equally significant was the absence of any proved motive, especially when the complainant himself admitted that the appellant and the deceased were friends without prior enmity. The medical evidence also contradicted the prosecution’s version, as the doctor specifically ruled out the possibility that the fatal injury could have been caused in the manner alleged by the prosecution. Additionally, the Court noticed that the deceased had an exceptionally high blood alcohol concentration and was found lying face down in a drain, making an accidental fall a plausible alternative explanation for the injuries.
Reaffirming the settled principles governing cases based entirely on circumstantial evidence, the High Court relied upon State of U.P. v. Satish regarding the limited application of the last seen theory and Kali Ram v. State of Himachal Pradesh to reiterate that if two reasonable views are possible, the one favourable to the accused must prevail. Since the prosecution failed to establish an uninterrupted chain of circumstances excluding every hypothesis consistent with innocence, the Court held that the conviction rested merely on conjectures and suspicion rather than proof beyond reasonable doubt. It consequently extended the benefit of doubt to the appellant and set aside his conviction and sentence.
Decision: The Punjab and Haryana High Court allowed the criminal appeal, set aside the appellant’s conviction and sentence under Section 302 IPC, and acquitted him by extending the benefit of doubt, holding that the prosecution had failed to establish a complete chain of circumstantial evidence proving guilt beyond reasonable doubt.